(4) CCDM 32.2.8.4, CCDM 32.2.8.4.2, Exhibit 32.2.8-5 and Exhibit 32.2.8-6 were revised to reflect current procedures for the
early release of publications.

(5) Former CCDM 32.2.8.5 was deleted to remove references to the expedited published guidance program.

(6) Former Exhibits 32.2.8–1 and 32.2.8–2 were deleted in favor of hyperlinks to fillable versions of Form 12971 and Form
12972.

(7) Exhibit 32.2.8–4 was updated.

(8) Exhibit 32.2.8–1, Exhibit 32.2.8–4, Exhibit 32.2.8-5 and tables were made compliant with Section 508 of the Rehabilitation
Act. Website addresses were updated and hyperlinks to sites and references were inserted.

Effect on Other Documents

CCDM 32.2.8 dated August 11, 2004 is superseded.

Audience

Chief Counsel

Effective Date

(09-23-2011)

Deborah A. ButlerAssociate Chief Counsel (Procedure & Administration)

32.2.8.1
(09-23-2011)Submission to the Bulletin Unit

When all clearances have been obtained, the proposed publication item is ready for publishing in the IRB.

Prior to submitting the package to the Bulletin Unit for publication, the drafting attorney will prepare the report to GAO
and Congress. See CCDM 32.2.8.2.

The drafting attorney is also responsible for removing all "hidden"
codes from the word processing files of the document submitted to the Bulletin Unit to prevent readers from viewing prior
changes to the document.

Instructions for removing hidden codes.

Microsoft Word documents: Pull up the approved version of the document, which reflects all changes to the document.

On the eWord Toolbar: Select Purge.

When the Purged Data Report message window appears, click OK.The purged document will be displayed and stored in the same directory as the original file. The purged document’s filename
will be the same as the original file with "(checked)"
added. For example, RR-XXXXXX-XX (checked).doc.

After removing any hidden codes, the drafting attorney prepares the package for submission to the Bulletin Unit. The copies
of the publication submitted to the Bulletin Unit must not contain the control (CASE-MIS) number, the draft date, or printer’s footnotes. When using the eWord Chief Counsel MACROs,
the control number and draft date will be deleted from the final version of the publication item when the drafting attorney
submits the publication item to Counsel’s content management system (Documentum).

Instructions for removing control number and draft date. Once the publication item is ready to be submitted to the Bulletin
Unit, the drafting attorney should:

Select the Submit button on the eWord toolbar.

Documentum will delete the first line of the document, including the CASE-MIS number and draft date, from the document and
rename the file using the CASE-MIS number.

The drafting attorney should print this document and provide the printed document to the Bulletin Unit.

Additionally, Documentum will create an XML file containing the publication item and send the drafting attorney an email,
shortly after submission, advising the drafting attorney how that file can be retrieved.

The XML file can be provided electronically to the Bulletin Unit (All documents printed in the IRB are converted to XML prior
to publication. If Counsel does not provide an XML file, the Bulletin Unit must transcribe the file. Thus, sending the XML
file electronically will save the Bulletin Unit processing time).

Questions on this process may be forwarded to the Macro development team at Macro.Inbox@irscounsel.treas.gov

The assigned reviewer in the Associate Office is responsible for ensuring that the final proposed publication reflects the
changes recommended at the various levels of review and that the submission package is complete (including the index and highlight
entries on Form 12972). Once the assigned reviewer approves, the reviewer will sign Form 12971. If the index or highlight
entries on Form 12972 are not completed, the Bulletin Unit will return the form to the drafting attorney to complete those
sections of the form.

The Associate office forwards the submission package to the Bulletin Unit (Room 6516).

Manuscripts for the IRB must be prepared using Microsoft Word, the standard word processing application for all of the Office
of Chief Counsel. The Bulletin Unit is authorized to return any manuscript to the drafting attorney if the material does not
meet the standards of acceptability for submission to the printer.

When the Associate office forwards the submission package to the Bulletin Unit (or to Media Relations for an early drop, see
CCDM 32.2.8.4.2), the Associate office should inform the following addresses by email of the pending publication:

The Chief Counsel

The Deputy Chief Counsel

All Special Counsel, Senior Counsel, and Senior Legal Counsel to the Chief Counsel

32.2.8.2
(09-23-2011)Congressional Review of Rules

The Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) added chapter 8 to title 5, United States Code (Congressional
Review Act). The Congressional Review Act (CRA) provides that no final rule can become effective until the issuing agency
submits a report containing certain information to the House of Representatives, the Senate, and the Comptroller General of
the GAO.

The Service meets its Congressional Review Act notice requirement by submitting a Submission of Federal Rules Under the Congressional
Review Act Form (see Exhibit 32.2.8-1 for a sample CRA form and Exhibit 32.2.8-2 for instructions for completing the CRA form),
the rule, and other attachments, to Congressional and GAO representatives. The drafting attorney must complete the CRA form.
The Publications and Regulations Branch arranges delivery of CRA forms, with attachments, to the House of Representatives,
the Senate, and the Comptroller General of the GAO within one business day of receipt.

Note:

No publication should be delivered for publication until a completed report is prepared and approved.

A rule is defined by SBREFA as the whole or a part of an agency statement of general or particular applicability and future
effect designed to implement, interpret, or prescribe law or policy or describing the organization, procedure, or practice
requirements of an agency. SBREFA provides specifically that the following are not rules for purposes of the congressional
review procedures:

Any rule of particular applicability

Any rule relating to agency management or personnel

Any rule of agency organization, procedure, or practice that does not substantially affect the rights or obligations of nonagency
parties.

Revenue rulings and revenue procedures are generally subject to SBREFA, and must be submitted for congressional review before
they can become effective. Certain ministerial revenue rulings and revenue procedures are exempt from the congressional review
provisions. As a matter of administrative convenience, however, all revenue rulings and revenue procedures will be treated
as rules that must be reported to GAO and Congress.

Notices, announcements, and news releases are generally not subject to congressional review.

Note:

Whether a notice or announcement is considered a rule subject to reporting is determined on a case-by-case basis. Notices
or announcements relating to error corrections, personnel matters, or proposed rules generally will not be considered rules.

The drafting attorney must prepare the following and deliver them to the Publications and Regulations Branch (CC:PA:LPD:PR),
room 5203, before 11 a.m. on the earliest of the date that the rule is released to the tax services, published in the IRB,
or otherwise made available to the public. Four CRA reports, each report consisting of the following documents in the order
listed (from top to bottom):

The completed CRA form

A copy of a concise summary of the rule

An unsigned copy of the final version of the rule

For the GAO package only, if the rule is a major rule, a copy of the cost benefit analysis

These four CRA reports are for:

President, United States Senate

Speaker, United States House of Representatives

General Counsel, GAO

Publications and Regulations Branch files

For the first three listed recipients of the CRA reports, type the recipient’s name and title in the upper right corner of
the CRA form for that recipient.

Five additional copies of the completed CRA form (without the concise summary or a copy of the rule). Type each recipient’s
name and title in the upper right corner of each of these five CRA forms. These five recipients (courtesy copy recipients)
receive only a copy of the CRA form, without the rule or concise summary. These five CRA forms are for:

Chairman, Committee on Ways and Means

Ranking Minority Member, Committee on Ways and Means

Chairman, Committee on Finance

Ranking Minority Member, Committee on Finance

Chief of Staff, Joint Committee on Taxation

Each day, the Publications and Regulations Branch prepares an "Acknowledgment of Receipt"
form (original and two copies), listing the documents being submitted under the CRA, for each of the following: (1) President,
United States Senate, and (2) Speaker, U.S. House of Representatives. By 2:00 p.m. the Publications and Regulations Branch
delivers the Acknowledgments of Receipt (original and one copy) and the listed CRA reports (Acknowledgment of Receipt packages)
for the President, U.S. Senate, and the Speaker, U.S. House of Representatives, to the IRS Legislative Affairs office. Personnel
in the IRS Legislative Affairs office deliver the CRA reports to those Congressional offices (usually within one business
day) and get a representative of each of those Congressional offices to sign the Acknowledgment of Receipt forms. IRS Legislative
Affairs returns the signed Acknowledgment of Receipt forms to the Publications and Regulations Branch box in the Office of
IRS Legislative Affairs.

The Publications and Regulations Branch maintains records of all CRA submissions and signed Acknowledgment of Receipt forms,
and follows up with the IRS Legislative Affairs office on any outstanding Acknowledgment of Receipt forms.

The Publications and Regulations Branch sends a CRA package to the General Counsel, GAO.

The Publications and Regulations Branch faxes the CRA forms to the offices of the five courtesy copy recipients and verifies
that each fax confirmation shows that the submission was properly transmitted in its entirety.

The Publications and Regulations Branch sends both signed Acknowledgment of Receipt forms (signed by the offices of the President,
United States Senate, and the Speaker, U.S. House of Representatives), to the drafting attorney to retain in the publication’s
background file. If an Acknowledgment of Receipt form lists more than one CRA report, the Publications and Regulations Branch
sends the original signed form to the drafting attorney for the first listed document and a copy of the signed form to the
drafting attorney for each other CRA report listed on the form. The Publications and Regulations Branch retains a copy of
each signed Acknowledgment of Receipt form and a copy of each related CRA report. The Publications and Regulations Branch
also sends the Acknowledgement of Receipt form signed by the Office of the General Counsel, GAO to the drafting attorney for
retention in the publication’s background file, and retains a copy together with the related CRA report, in the Publications
and Regulations Branch files.

It is the responsibility of the drafting attorney to ensure that the Acknowledgment of Receipt forms are placed in the regulation’s
legal file. If the attorney does not receive the acknowledgments within 10 days of delivering the CRA form to the Publications
and Regulations Branch, the attorney should follow up with the Publications and Regulations Branch to determine status of
the forms and to verify the CRA reports were submitted. It is critical that the acknowledgments are retained in the event
there is any question over whether the IRS complied with the CRA.

32.2.8.3
(09-23-2011)Processing Material

The Bulletin Unit prepares the proposed publication for printing. When appropriate, the Bulletin Unit may ask the Associate
office to do a proof check of the manuscript and the IRB highlights before it goes to the printer.

Publication timetable. There is a normal period of approximately 3 weeks between the time a publication is received by the
Bulletin Unit and its publication in the IRB. In extraordinary circumstances, it is possible for a publication to be published
in less time than the normal 3 week time period.

32.2.8.4
(09-23-2011)Early Release of a Publication

In almost all cases it is desirable to release a publication prior to publishing in the IRB. Accordingly, the proposed publication
should be prepublished (that is, made public by or in a news release or by way of an "early drop"
before it is published in the IRB). If Media Relations or higher level official feels that a news release is unnecessary,
an advance copy of a publication may be provided to the commercial tax services through the Media Relations office with a
notation as to which IRB it will appear in. This latter procedure is commonly referred to as a "drop"
or "early drop"
. See CCDM 32.2.8.4.2. In certain instances, the release of a publication through commercial tax services is not feasible,
for example, when a legal effective date is tied to the date of the publication or when publication will affect market conditions.
A decision to not release a publication in advance of appearing in the IRB must be approved by an Associate Chief Counsel.

32.2.8.4.1
(08-11-2004)News Releases

Most news releases involving issues within the jurisdiction of the Associate Chief Counsel are used to release to the public
a publication and contain no more than a plain-language statement of the information being published and a reference to the
IRB in which the publication will appear. The drafting attorney should contact the Media Relations office at least one week
before the anticipated release of the publication and work with that office in the preparation of the news release.

See Exhibit 32.2.3-7, Format for Typed Draft of Proposed News Release, for a sample news release.

A news release may be appropriate if the publication:

Has a broad target audience

Has high popular interest

Will be a controversial media issue

Will require a significant education or compliance effort

32.2.8.4.2
(09-23-2011)"Drop"
or "Early Drop"
of a Publication

This procedure provides advance copies of the publication to the commercial tax services through the Media Relations office
(see Exhibit 32.2.8-3)

After all approvals to publish have been secured, the drafting attorney prepares a form, Request for Advance Release of IRB
Item to the News Media (see Exhibit 32.2.8-4).

The drafting attorney emails an electronic version of the publication to Media Relations. It is very important that the drafting
attorney purge the electronic version of the publication of any hidden codes before submitting the proposed publication to
Media Relations. See CCDM 32.2.8.1(5) for instructions on how to remove hidden codes from the electronic version submitted
to Media Relations. In addition, the electronic version and the copies of the publication to be dropped must not contain the control number, the draft date, or printer’s footnotes. See CCDM 32.2.8.1(7) for instructions on how to remove
the control number and draft date if using the eWord Chief Counsel MACROs. The copies must , however, contain the publication number.

The electronic version of the publication should be emailed to Media Relations and the form should be delivered to the office
listed in Exhibit 32.2.8-3. Media Relations disseminates at 10 AM and 2 PM and needs the materials at least 90 minutes before
release. Because of processing issues, releases after 2 PM are burdensome for both the Service and the media and are done
in only rare, emergency situations.

General — Certain proposed publications involving only ministerial matters (such as, applicable federal interest rates and
monthly bond factor amounts) may be published without referral to the Chief Counsel, Commissioner, and, in most cases, without
referral to Treasury. The branch should consult the Techmis IRS/Treasury Business Plan Appendix-Ministerial Rulings report
to determine whether, and to what extent, approval may be waived for a publication item.

After the review and approval of a proposed ministerial publication by the Associate Chief Counsel, the branch will prepare
the publication package for submission to the Bulletin Unit for publication.

32.2.8.6
(08-11-2004)Processing Public Comments

On occasion, the public is offered the opportunity to provide comments on proposed publications, usually proposed revenue
rulings or proposed revenue procedures. The drafting attorney will consider any comments received during the development of
the proposed publication.

When a request for comments is solicited (for example, in a notice or announcement) interested persons should be given the
following information on how to submit comments:

Note:

Commenters should be instructed to include the identification number of the publication in both the body of the comment and
on the email subject line.

When considering public comments, steps should be taken to identify the source and content of the comments in materials that
are reviewed, when appropriate. For example, it may be appropriate to make an entry in the BIN to reflect public comments
that are considered in the development of the project.

32.2.8.7
(08-11-2004)Mass Obsoleting of Revenue Rulings/Procedures

The Service has a continuing program to review its publications in order to identify and publish lists of those publications
that, although not specifically revoked or superseded, are no longer determinative because:

The applicable statutory provisions or regulations have been changed or repealed

The ruling position is specifically covered by statute, regulation, or subsequent published position

The facts set forth no longer exist or are not sufficiently described to permit clear application of the current statute and
regulations

Exhibit 32.2.8-5 provides a pattern for use in obsoleting these publications.

All CRA forms and packages are due to the Regulations Unit before 11:00 a.m. on the date the rule is issued (the date a TD
is filed at the OFR).

Instructions for Completing the 1st Page of the Congressional Review Act (CRA) Form:

Select President of the Senate, Speaker of the House of Representatives, or GAO. Prepare a CRA form for each one.

1. Name of Department or Agency — Department of the Treasury

2. Subdivision or Office — Internal Revenue Service

3. Rule Title — State the Rule Title exactly as it appears on the rule. If the rule does not contain a title, the attorney should create
a brief descriptive title. Do not include the RIN, TD number, Rev. Rul. or Rev. Proc. number, etc. in the title.

4. Regulation Identification Number (RIN) or Other Unique Number (if applicable)

TDs:

Use the Regulation Identification Number (RIN) and the Treasury decision (TD) number. Place the TD number in parentheses following
the RIN. If submitting multiple actions under one RIN, add information that identifies each action.

Other than TDs:

Use the agency’s unique identification number, such as the revenue ruling number, revenue procedure number AOD number, etc.
Do not include the IRB citation.If there is no agency unique identification number, leave blank. Do not use a CASE-MIS ID number or a Uniform Issue List (UIL)
number.

EXAMPLES:

TD: RIN 1545-BBI9 (TD 9020)

Revenue Ruling: Rev. Rul. 2010-80

Revenue Procedure: Rev. Proc. 2010-70

Notice: Notice 2010-73

Announcement: Announcement 2010-40

Action on Decision: AOD 2010-5

Appeals Settlement Guidelines: Leave blank

Coordinated Issue Paper: Leave blank

Market Segment Specialization Papers: Leave blank

5. Major Rule — Indicate whether the rule is designated as a "major"
or "non-major"
rule pursuant to the CRA

A major rule is a rule that is likely to result in:

An annual effect on the economy of $100,000,000 or more;

A major increase in costs or prices for consumers, individual industries, Federal, State, or local government agencies, or
geographic regions; or

Significant adverse effects on competition, employment, investment, productivity, innovation, or on the ability of US-based
enterprises to compete with foreign-based enterprises in domestic and export markets.

If the rule is a "major rule"
, pursuant to 5 U.S.C 801, the effective date of the rule cannot be earlier than 60 days after the rule is delivered to
the House, Senate and the GAO.

IRS rules are rarely major rules because the effect of most IRS rules is due to the underlying statute, rather than to the
regulation. See CCDM 32.1.6.11.2.5(12), Congressional Review Act Forms. Consult the Chief, Regulations Unit, before responding
that the document is a major rule.

A non-major rule is a rule that is not a major rule. Almost all IRS documents are non-major rules.

6. Final Rule — A final rule amends the Code of Federal Regulations (CFR).

7. Public Comments — If the agency solicited public comments (for example, by publishing a prior ANPRM or NPRM, Notice, by holding a public
hearing or meeting, by taking a survey, or by conducting an advisory committee hearing) respond "Yes."
Otherwise, respond "No."

8. Priority of Regulation

TDs:

Indicate the priority to which the regulation was, or will be, assigned in the Semiannual Agenda (see below). Most IRS regulations
are categorized as "Substantive, Nonsignificant."

A regulation is ECONOMICALLY SIGNIFICANT if is it expected to have an annual effect on the economy of $100,000,000 or more
or will adversely affect in a material way the economy; a sector of the economy; productivity, competition; jobs; the environment,
public health or safety; or State, local, or tribal governments or communities. This definition is similar, but not identical,
to the definition of a major rule (above).

A regulation is SIGNIFICANT if it is not Economically Significant and (i) the agency considers the regulation significant,
(ii) the regulation is a priority of the head of the agency, or (iii) the agency anticipates the regulation will be reviewed
under Executive Order 12866. A significant regulation may be identified as a Major or Non-major rule.

A regulation is SUBSTANTIVE, NONSIGNIFICANT if it has substantive impacts but the magnitude of the impact is less than significant.
These regulations are most likely not Economically Significant, will most likely not be reviewed under E.O. 12866, and are
not, at present, a priority of the head of the agency. A Substantive, Nonsignificant regulation is always identified as a
Non-major rule.

A regulation is ROUTINE AND FREQUENT if it is a specific case of a multiple recurring application of a regulatory program
in the CFR and it does not alter the body of the regulation. (Note: If an individual regulation that normally falls into the
Routine and Frequent category is submitted to OMB for review, the rulemaking should be classified as Economically Significant
or Other Significant.) A Routine and Frequent regulation is always identified as a Non-major rule.

A regulation is INFORMATIONAL/ADMINISTRATIVE/OTHER if it is primarily informational or pertains to agency matters not central
to accomplishing the agency's regulatory mandate but that the agency places in the Semiannual Agenda to inform the public
of the activity. An Informational/Administrative/Other regulation is always identified as a Non-major rule. If the TD is categorized
as "Routine and Frequent, or Informational/Administrative/Other"
, do not complete the second page of the CRA form.

Other than TDs:

Leave blank. This question relates only to TDs.

9. Effective Date

TDs:

Enter the Effective Date as stated in the DATES caption in the preamble.

Note:

If the rule is a "major rule,"
pursuant to 5 U.S.C 801, the effective date of the rule cannot be earlier than 60 days after the rule is delivered to
(and actually received by) the House, Senate and the GAO.

Other than TDs:

If the document contains an effective date or applicability date in the text, the Effective Date for the CRA form is the effective
date or applicability date as stated in the document. If the rule contains multiple effective dates, enter the earliest effective
date.If the document does not contain an effective date or applicability date in the text, leave the Effective Date section on
the CRA form blank (do not enter N/A; do not enter the publication or issuance date of the document).Examples:

A Revenue Procedure states that it is applicable to transactions entered into after December 31, 2010. The Effective Date
for the CRA form is January 1, 2011.

A Notice provides guidance for computing certain amounts for a calendar quarter. The Effective Date for the CRA form is the
first day of that calendar quarter.

A Revenue Ruling or Coordinated Issue Paper provides guidance to be applied on a retroactive (without stating a specific date)
and a prospective basis. Leave the Effective Date section on the CRA form blank. Do not enter "N/A ."
Do not enter the publication date or date of issuance.

Submitted By — The Chief, Publications and Regulations Branch signs the form.

Enter that individual’s name and title as follows:

[insert name]Chief, Publications and Regulations Branch

Following the signature, name, and title, type:

If you have any questions, please contact [insert attorney’s name] at [insert attorney’s 10-digit phone number].

Instructions for Completing the 2nd Page of the Congressional Review Act (CRA) Form

Reminder:

For TDs only, if the TD is categorized as "Routine and Frequent"
, or "Informational Administrative/Other"
, (1st page, # 8) do not complete the second page of the CRA form.

A. If the final rule is a significant regulatory action or a major rule, the agency must prepare a cost and benefit analysis
for OMB’s review.

TDs:

Answer "Yes"
if the agency prepared an analysis of costs and benefits. If the rule is neither a significant regulatory action nor a
major rule, answer "No."

Revenue Rulings, Revenue Procedures, Notices and Announcements:

If the rule is neither a significant regulatory action nor a major rule, answer "No."

Action on Decision:

Answer "N/A."

Coordinated Issue Papers:

Answer "N/A."

Market Segment Specialization Papers:

Answer "N/A."

B. TDs

If the final rule is subject to the Regulatory Flexibility Act, the agency must prepare a final regulatory flexibility analysis
or certify that the rule will not have a significant economic impact on a substantial number of small entities.If, by the final rule stage, the agency certifies that a regulatory flexibility analysis is not required, answer "Yes"
to question B.1. and "N/A"
to question B.2.If, by the final rule state, the agency prepared a final regulatory flexibility analysis, answer "N/A"
to question B.1. and "Yes"
to question B.2.If the final rule is not subject to the Regulatory Flexibility Act, answer "N/A"
to both questions B.1. and B.2.

Other than TDs: Answer "N/A"
to both questions B.1 and B.2.

C. TDs:

If the final rule includes a mandate that will result in costs exceeding $100,000,000 in any one year, section 202 of the
Unfunded Mandates Reform Act of 1995 (UMRA) requires agencies to prepare a "written statement."
If the final rule is subject to the UMRA and the agency prepared a "written statement,"
answer "Yes"
to question C. If the final rule is subject to the UMRA and agency did not prepare the "written statement,"
answer "No."
If the final rule is not subject to UMRA, answer "N/A."
Virtually all IRS regulations are not subject to UMRA.

Other than TDs: Answer "N/A."

D. For all documents: Answer "N/A."

E. For TDs and other published guidance (revenue rulings, revenue procedures, notices):

If the rule contains a collection of information requirement subject to the Paperwork Reduction Act of 1995, answer "Yes."
If it does not, answer "No."

For documents that are neither TDs nor other published guidance: Answer "N/A."

F. TDs:

For each Executive Order (E.O.) answer "Yes"
or "No"
§ depending on whether the E.O. was discussed in the preamble (regardless of whether the E.O. applies or does not apply
to the regulation). In the space provided, list all other statutes (for example, IRC § 7805) and other executive orders addressed
in the preamble. The preamble to IRS regulations routinely address E.O. 12866 and 26 U.S.C. § 7805.

Other than TDs: Answer "N/A"
for each Executive Order.

Preparation of CRA Packages and Additional Copies of the CRA Form:

1. Assemble three packages, one each for (i) the President, United States Senate, (ii) the Speaker, U.S. House of Representatives,
and (iii) the General Counsel, GAO. Each package contains the following documents in the order listed, from top to bottom:

Completed CRA form;

Concise summary of the rule;

A copy of the rule; and

Any other attachment(s) (rarely will there will be any other attachment).

2. Make a copy of one of the packages for retention in the Regulations Unit.

3. Make five copies of one of completed CRA forms (preferably either the one for the President, U.S. Senate, or the one for
the Speaker, U.S. House of Representatives). Type each of the following recipients. names and titles on the upper right corner
of each of the five copies:

These five recipients receive only a copy of the CRA form, without any attachments.

Acknowledgment of Receipt Forms

The Publication and Regulations Branch delivers to the drafting attorney Acknowledgement of Receipt forms from the Senate
House of Representatives and GAO. If the drafting attorney does not receive the acknowledgment within 10 days from when the
attorney delivered the CRA form to the Publications and Regulations Branch, the attorney must contact the Publications and
Regulations Branch to obtain the acknowledgments. The drafting attorney must file all three acknowledgments in the legal file
for the regulation project. It is critical that the acknowledgments are retained in the event that there is any question over
whether the IRS complied with the CRA.

Exhibit 32.2.8-3
Procedures for Release of Guidance to the News Media (Drops)

RELEASE OF GUIDANCE TO THE NEWS MEDIA

("DROPS"
)

ADVANCE COORDINATION

Please alert Media Relations at least one week before anticipated release if the guidance affects a broad target audience,
would be of high popular interest, covers a controversial issue, or requires significant education or compliance effort.

Note on the Request sheet if either a Treasury or IRS release is in process.

SCHEDULE

Media Relations issues guidance at 10 AM and 2 PM; because of processing issues, releases after 2 PM are burdensome for both
IRS and the media and are done only in cases of real urgency.

Media Relations needs Regs and Fed. Register notices by 1:30 PM. There is no point in sending electronic files after the day
regs are filed, as the tax services will have obtained the text from the Register and printed it.

ELECTRONIC FILE FORMAT

Remove Draft Date and Case Number from the document.

MS Word is the preferred format.

The preferred spacing format is single-spaced.

SUMMARY DESCRIPTION

One or two "plain English"
sentences on the subject of the drop.

Not a "cut & paste"
of the document’s first paragraph or its conclusion.

Include key terms and/or their "popular"
names.

COUNSEL CONTACTS

Direct Phone # should be included (not Branch or general office line) for: • Person responsible for file/disk/paper materials • Attorney (and a backup) authorized to speak w/ media (someone must be available the day materials are released and the next business day)

Part ISection 7805.--Rules and Regulations26 C.F.R. 301.7805-1: Rules and regulations.

Rev. Rul.

The Internal Revenue Service is continuing its program of reviewing revenue rulings published in the Internal Revenue Bulletin
to identify and publish lists of those rulings that, although not specifically revoked or superseded, are no longer considered
determinative because: (1) the applicable statutory provisions or regulations have been changed or repealed; (2) the ruling
position is specifically covered by a statute, regulation, or subsequent published position; or (3) the facts set forth no
longer exist or are not sufficiently described to permit clear application of the current statute and regulations.

This revenue ruling publishes a list of rulings dealing with [insert subject matter].

The listed revenue rulings have been identified under the Service's review program as no longer being determinative.

The Service will continue to review other revenue rulings relating to [insert subject matter] to identify those that, for
the reasons stated above, are inapplicable to future transactions. Therefore, failure to include any particular revenue ruling
in the above list should not be construed as an indication that the revenue ruling necessarily is determinative with respect
to future transactions.

DRAFTING INFORMATION

The principal author of this revenue ruling is __ of the Office of Associate Chief Counsel (__). For further information
regarding this ruling contact __ on (202) _ (not a toll-free call.)